THE PRESIDENT: Do any of the other defendants' counsel want to ask questions?

Then, do the Prosecution wish to cross-examine?

MR. JUSTICE ROBERT H. JACKSON (Chief of Counsel for the United States):
Defendant, your counsel divided your examination into two parts which he
described first as your personal responsibilities, and secondly as the
political part of the case, and I will follow the same division.

You have stated a good many of the matters for which you were not responsible,
and I want to make clear just what your sphere of responsibility was.

You were not only a member of the Nazi Party after 1932, but you held
high rank in the Party, did you not?

SPEER: Correct.

MR. JUSTICE JACKSON: And what was the position which you held in the
Party?

SPEER: I have already mentioned that during my pre-trial interrogations.
Temporarily in 1934 I became a department head in the German Labor Front
and dealt with the improvement of labor conditions in German factories.
Then I was in charge of public works on the staff of Hess. I gave up both
these activities in 1941. Notes of the conference I had with Hitler about
this are available. After 2/8/1942 I automatically became Todt's successor
in the central office for technical matters in the Reichsleitung of the
NSDAP.

MR. JUSTICE JACKSON: And what was your official title?

SPEER: Party titles had just been introduced, and they were so complicated
that I cannot tell you at the moment what they were. But the work I did
there was that of a department chief in the Reichsleitung of the NSDAP.
My title was Hauptdienstleiter or something of the kind.

MR. JUSTICE JACKSON: In the 1943 directory it would appear that you
were head of the "Hauptamt fur Technik."

MR. JUSTICE JACKSON: And your rank appears to be "Oberbefehlsleiter"?

SPEER: Yes, that is quite possible.

MR. JUSTICE JACKSON: Which as I understand corresponds 1 roughly to
a lieutenant general in the army?

SPEER: Well, compared to the other tasks I had it was very little.

MR. JUSTICE JACKSON: And you attended Party functions from time to time
and were informed in a general way as to the Party program, were you not?

SPEER: Before 1942 I joined in the various Party rallies here in Nuremberg
because I had to take part in them as an architect, and of course besides
this I was generally present at official Party meetings or Reichstag sessions.

MR. JUSTICE JACKSON: And you heard discussed, and were generally familiar
with, the program of the Nazi Party in its broad outlines, were you not?

SPEER: Of course.

MR. JUSTICE JACKSON: Youthere is some question as to just what your
relation to the SS was. Will you tell me whether you were a member of the
SS?

SPEER: No, I was not a member of the SS.

MR. JUSTICE JACKSON: You filled out an application at one time, or one
was filled out for you, and you never went through with it, I believe,
or something of that sort.

SPEER: That was in 1943 when Himmler wanted me to get a high rank in
the SS. He had often wanted it before when I was still an architect. I
got out of it by saying that I was willing to be an ordinary SS man under
him because I had already been an SS man before. Thereupon, Gruppenfuhrer
Wolff provisionally filled out an application form and wanted to know what
my previous SS activities had been in 1932. It came up during his inquiries
that in those days I was never registered as a member of the SS, and because
of this they did not insist on my joining as I did not want to become a
new member now.

MR. JUSTICE JACKSON: And why did you not want to be a member of the
SS, which was after all one of the important Party formations?

SPEER: No, I became well known for turning down all these honorary ranks.
I did not want them because I felt that one should only hold a rank where
one had responsibility.

MR. JUSTICE JACKSON: And you did not want any responsibility in the
SS?

SPEER: I had too little contact with the SS, and did not want any responsibility
in that connection.

MR. JUSTICE JACKSON: Now there has been some testimony about your relation
to concentration camps, and, as I understand it, you have said to us that
you did use and encourage the use of forced labor from the concentration
camps.

SPEER: Yes, we did use it in the German armament industry.

MR. JUSTICE JACKSON: And I think you also recommended that persons in
labor camps who were slackers be sent to the concentration camps, did you
not?

SPEER: That was the question of the so-called "Bummelanten," and by
that name we meant workers who did not get to their work on time or who
pretended to be ill. Severe measures were taken against such workers during
the war, and I approved of these measures.

MR. JUSTICE JACKSON: In fact, in the 10/30/1942 meeting of the Central
Planning Board you brought the subject up in the following terms, did you
notquoting Speer:

"We must also discuss the slackers. Ley has ascertained that the sick
list decreases to one-fourth or one-fifth in factories where doctors are
on the staff who examine the sick men. There is nothing to be said against
SS and Police taking drastic steps and putting those known to be slackers
into concentration camp factories. There is no alternative. Let it happen
several times, and the news will soon get around."

That was your recommendation?

SPEER: Correct.

MR. JUSTICE JACKSON: In other words, the workmen stood in considerable
terror of concentration camps, and you wanted to take advantage of that
to keep them at their work, did you not?

SPEER: It is certain that concentration camps had a bad reputation with
us, and the transfer to a concentration camp, or threat of such a possibility,
was bound to reduce the number of absentees in the factories right from
the beginning. But at that meeting, as I already said yesterday, there
was nothing further said about it. It was one of the many remarks one can
make in wartime when one is upset.

MR. JUSTICE JACKSON: However, it is very clearand if I misinterpret
you I give you the chance to correct methat you understood the very bad
reputation that the concentration camp had among the workmen and that the
concentration camps were regarded as being much more severe than the labor
camps as places to be in.

SPEER: That is correct. I knew that. I did not know, of course, what
I have heard during this Trial, but the other thing was a generally known
fact.

MR. JUSTICE JACKSON: Well, it was known throughout Germany, was it not,
that the concentration camps were pretty tough places to be put?

SPEER: Yes, but not to the extent which has been revealed in this Trial.

MR. JUSTICE JACKSON: And the bad reputation of the concentration camp,
as a matter of fact, was a part of its usefulness in making people fearful
of being sent there, was it not?

SPEER: No doubt concentration camps were a means, a menace used to keep
order.

MR. JUSTICE JACKSON: And to keep people at work?

SPEER: I would not like to put it in that way. I assert that a great
number of the foreign workers in our country did their work quite voluntarily
once they had come to Germany.

MR. JUSTICE JACKSON: Well, we will take that up later. You used- the
concentration camp labor in production to the extent that you were required
to divide the proceeds of the labor with Himmler, did you not?

SPEER: That I did not understand.

MR. JUSTICE JACKSON: Well, you made an agreement finally with Himmler
that he should have 5 percent, or roughly 5 percent, of the production
of the concentration camp labor while you would get for your work 95 percent?

SPEER: No, that is not quite true.

MR. JUSTICE JACKSON: Well, tell me how it was. That is what the documents
indicate, if I read them aright.

SPEER: Yes, it is put that way in the Fuhrer minutes, but I s should
like to explain the meaning to you. Himmler, as I said yesterday wanted
to build factories of his own in his concentration -camps. Then he would
have been able to produce arms without any outside control, which Hitler,
of course, knew. The 5 percent arms production which was to have been handed
to Himmler was to a certain extent a compensation for the fact that he
himself gave up the idea of building factories in the camps. From the psychological
; point of view it was not so simple for me to get Himmler to give up this
idea when he kept on reminding Hitler of it. I was hoping that he would
be satisfied with the 5 percent arms production we were going to give him.
Actually this 5 percent was never handed over. We managed things quietly
with the Operations Staff of the OKW and with General Buhle, so that he
never got the arms at all.

MR. JUSTICE JACKSON: Well, I am not criticizing the bargain, you understand.
I don't doubt you did very well to get 95 percent, but the point is that
Himmler was using, with your knowledge, concentration camp labor to manufacture
arms, or was proposing to do so, and you wanted to keep that production
within your control?

SPEER: Could the translation come through a bit clearer? Would you please
repeat that?

MR. JUSTICE JACKSON: You knew at this time that Himmler was using concentration
camp labor to carry on independent industry and that he proposed to go
into the armament industry in order to have a source of supply of arms
for his own SS?

MR. JUSTICE JACKSON: You also knew the policy of the Nazi Party and
the policy of the Government towards the Jews, did you not?

SPEER: I knew that the National Socialist Party was anti-Semitic, and
I knew that the Jews were being evacuated from Germany.

MR. JUSTICE JACKSON: In fact, you participated in that evacuation, did
you not?

MR. JUSTICE JACKSON: Well, I gather that impression from Document L-156,
Exhibit RF-1522, a letter from the Plenipotentiary for the Allocation of
Labor which is dated 3/26/1943, which you have no doubt seen. You may see
it again, if you wish. In which he says...

SPEER: I know it.

MR. JUSTICE JACKSON: "At the end of February, the Reichsfuhrer SS, in
agreement with myself and the Reich Minister for armaments and munitions,
for reasons of state security, has removed from their places of work all
Jews who were still working freely and not in camps, and either transferred
them to a labor corps or collected them for removal." Was that a correct
representation of your activity?

MR. JUSTICE JACKSON: Will you tell me what part you had in that? There
is no question that they were put into labor corps or collected for removal,
is there?

SPEER: That is correct.

MR. JUSTICE JACKSON: Now you say you did not do it, so will you tell
me who did?

SPEER: It was a fairly long business. When, in 2/1942, I took over my
new office, the Party was already insisting that Jews who were still working
in armament factories should be removed from them. I objected at the time,
and managed to get Bormann to issue a circular letter to the effect that
these Jews might go on being employed in armament factories and that Party
offices were prohibited from accusing the heads of these firms on political
grounds because of the Jews working there. It was the Gauleiter who made
such political accusations against the heads of concerns, and it was mostly
in the Gau Saxony and in the Gau Berlin. So after this the Jews could remain
in these plants.

Without having any authority to do so, I had had this circular letter
from the Party published in my news sheet to heads of factories and had
sent it to all concerned, so that I would in any case receive their complaints
if the Party should not obey the instruction. After that the problem was
left alone, until September or -October of 1942. At that time a conference
with Hitler took place, at which Sauckel also was present. At this conference
Hitler insisted emphatically that the Jews must now be removed from the
armament firms, and he gave orders for this to be donethis will be seen
from a Fuhrer protocol which has been preserved. In spite of this we managed
to keep the Jews on in factories and it was only in 3/1943, as this letter
shows, that resistance gave way and the Jews finally did have to get out.

I must point out to you that, as far as I can remember, it was not yet
a question of the Jewish problem as a whole, but in the years 1941 and
1942 Jews had gone to the armament factories to do important war work and
have an occupation of military importance; they were able to escape the
evacuation which at that time was.already in full swing. They were mostly
occupied in the electrical industry, and Geheimrat Bucher, of the electrical
industry that is AEG and Siemensno doubt lent a helping hand in order to
get the Jews taken on there in greater numbers. These Jews were completely
free and their families were still in their homes.

The letter by Gauleiter Sauckel you have before you was not, of course
submitted to me; and Sauckel says that he himself had not seen it. But
it is certainly true that I knew about it before action was taken; I knew
because the question had to be discussed as to how one should get replacements.
It is equally certain, though, that I also protested at the time at having
skilled labor removed from my armament industries because, apart from other
reasons, it was going to make things difficult for me.

MR. JUSTICE JACKSON: That is exactly the point that I want to emphasize.
As I understand it, you were struggling to get manpOWer enough to produce
the armaments to win a war for Germany.

MR. JUSTICE JACKSON: And this anti-Semitic campaign was so strong that
it took trained technicians away from you and disabled you from performing
your functions. Now, isn't that the fact?

SPEER: I did not understand the meaning of your question.

MR. JUSTICE JACKSON: Your problem of creating armaments to win the war
for Germany was made very much more difficult by this anti-Jewish campaign
which was being waged by others of your codefendants.

SPEER: That is a certainty; and it is equally clear that if the Jews
who were evacuated had been allowed to work for me, it would have been
a considerable advantage to me.

THE PRESIDENT: Mr. Justice Jackson, has it been proved who signed that
document, L-156? It has got a signature apparently on it.

MR. JUSTICE JACKSON: There is a signature on it, I believe the plenipotentiary
general for the employment of labor is my thought on it. We will look at
that.

THE PRESIDENT: Perhaps the defendant could tell what the signature is.

The document was shown to the defendant.]

SPEER: I do not know the man. Yes, he must be one of the smaller officials
in the offices of the Plenipotentiary for Labor, because I knew all the
immediate associates of Sauckel personally no; I beg your pardon, the document
comes from the Regierungsprasident in Koblenz, as I see here. Then it is
an assistant in the Government District of Koblenz, whom of course I did
not know.

MR. JUSTICE JACKSON: In any event, there is no question about the statement
as you have explained it?

SPEER: No.

MR. JUSTICE JACKSON: Now I want to ask you about the recruiting of forced
labor. As I understand it, you know about the deportation of l00000 Jews
from Hungary for subterranean airplane factories, and you told us in your
interrogation of 10/18/1945 that you made no objection to it. That is true,
is it not?

SPEER: That is true, yes.

MR. JUSTICE JACKSON: And you told us also, quite candidly, on that day
that it was no secret to you that a good deal of the manpower brought in
by Sauckel was brought in by illegal methods. That is also true, is it
not?

SPEER: I took great care at the time to notice what expression the interrogating
officer used; he used the expression "they came ; against their wish";
and that I confirmed.

MR. JUSTICE JACKSON: Did you not say that it was no secret to you that
they were brought in an illegal manner? Didn't you add that yourself?

SPEER: No, no. That was certainly not so.

MR. JUSTICE JACKSON: Well, in any event, you knew that at the Fuhrer
conference in August of 1942 the Fuhrer had approved of all coercive measures
for obtaining labor if they couldn't be i obtained on a voluntary basis,
and you knew that that program was carried out. You, as a matter of fact,
you did not give any particular attention to the legal side of this thing,
did you? You were 'after manpower; isn't that the fact?

SPEER: That is absolutely correct.

MR. JUSTICE JACKSON: And whether it was legal or illegal was not your
worry?

SPEER: I consider that in view of the whole war situation and j of our
views in general on this question it was justified.

MR. JUSTICE JACKSON: Yes, it was in accordance with the policy of the
Government, and that was as far as you inquired at the time, was it not?

SPEER: Yes. I am of the opinion that at the time I took over -my office,
in 2/1942, all the violations of international law, which laterwhich are
now brought up against me, had already been committed.

MR. JUSTICE JACKSON: And you don't question that you share a certain
responsibility for that program for bringing inwhether it is a legal responsibility
or not, in factfor bringing in this labor against its will? You don't deny
that, do you?

SPEER: The workers were brought to Germany largely against their will,
and I had no objection to their being brought to Germany against their
will. On the contrary, during the first period, until the autumn of 1942,
I certainly also took some pains to see that as many workers as possible
should be brought to Germany in this manner.

MR. JUSTICE JACKSON: You had some participation in the distribution
of this labor, did you not, as among different plants, different industries,
that were competing for labor?

SPEER: No. That would have to be explained in more detailI do not quite
understand it like that.

MR. JUSTICE JACKSON: Well, you finally entered into an agreement with
Sauckel, did you not, in reference to the distribution of the labor after
it reached the Reich?

SPEER: That was arranged according to the so-called priority grades.
I had to tell Sauckel, of course, in which of my programs labor was needed
most urgently. But that sort of thing was dealt with by general instructions.

MR. JUSTICE JACKSON: In other words, you established the priorities
of different industries in their claim for the labor when it came into
the Reich?

SPEER: That was a matter of course; naturally that had to be done.

MR. JUSTICE JACKSON: Yes. Now, as to the employment of prisoners of
war, youwhatever disagreement there may be about the exact figures, there
is no question, is there, that prisoners of war were used in the manufacture
of armament?

SPEER: No, only Russian prisoners of war and Italian military internees
were used for the production of arms. As for the use of French and other
prisoners of war in this production I had several conferences with Keitel
on the subject. And I must tell you that Keitel always adopted the view
that these prisoners of war could not be used in violation of the Geneva
Prisoner of War Convention. I can claim that on the strength of this fact
I no longer used my influence to see that these prisoners of war should
be used in armament industries in violation of the Geneva Convention. The
conception, of course, "production of arms" is very much open to argument.
It always depends on what position one takes, whether you have a wide conception
of "armaments" or a narrow one.

MR. JUSTICE JACKSON: Well, you succeeded to Dr. Todt's organization,
and you had all the powers that he had, did you not?

MR. JUSTICE JACKSON: And one of his directives was dated 10/31/1941,
a letter from the OKW which is in evidence here as Exhibit 214, Document
EC-194, which provides that the deputies of the Reich Minister for arms
and munitions are to be admitted to prisoner-of-war camps for the purpose
of selecting skilled workers. That was among your powers, was it not?

SPEER: No. That was a special action which Dr. Todt introduced on the
strength of an agreement with the OKW. It was dropped later, however.

MR. JUSTICE JACKSON: Now, on 4/22/1943, at the thirty-sixth meeting
of this Planning Board, you made this complaint, did you not, Herr Speer?
Quoting:

"There is a statement showing in what sectors the Russian POW's have
been distributed, and this statement is quite interesting. It shows that
the armament industry only received 30 percent. I always complained about
that." That is correct, is it not?

SPEER: I believe that has been wrongly translated. It should not say
"munitions industry"; it should say, "The armament industry received 30
percent."

MR. JUSTICE JACKSON: I said "armament."

SPEER: Yes. But this is still no proof that these prisoners of w-ar
were employed in violation of the Geneva Prisoner of War Convention, because
in the sector of the armament industry there was ample room to use these
workers for production articles which, in the sense of the Geneva Prisoner
of War Agreement, were not armament products. However, I believe that in
the case of the Russian prisoners of war, there was not the same value
attached to strict observance of the Geneva Convention as in the case of
prisoners from western countries.

MR. JUSTICE JACKSON: Is it your contention that the prisoners were not
usedI now speak of French prisoners of war that French prisoners of war
were not used in the manufacture of materials which directly contributed
to the war, or is it your contention that although they were used it was
legal under the Geneva Convention?

SPEER: As far as I know, French prisoners of war were not used contrary
to the rules of the Convention. I cannot check that, because my office
was not responsible for controlling the conditions of their employment.
During my numerous visits to factories, I never noticed that any prisoner
of war from the western territories was working directly on armament products.

MR. JUSTICE JACKSON: Just tell exactly what French prisoners of war
did do by way of manufacture. What were they working on?

SPEER: That I cannot answer. I already explained yesterday that the
allotment of prisoners of war, or foreign workers, or German workers to
a factory was not a matter for me to decide, but was carried out by the
labor office, together with the Stalag, when it was a question of prisoners
of war. I received only a general survey of the total number of workers
who had gone to the factories, and so I could get no idea of what types
of labor were being employed in each individual factory. So I cannot give
a satisfactory answer to your question.

MR. JUSTICE JACKSON: Now let us take the 50000 skilled workers that
you said yesterday you removed and put to work in a different location,
that Sauckel complained about. What did you put them to work at?

SPEER: Those were not prisoners of war.

MR. JUSTICE JACKSON: Let us take those workers. What were you doing
with them?

SPEER: Those workers had been working on the Atlantic Wall. From there
they were transferred to the Ruhr to repair the two dams which had been
destroyed by an air attack. I must say that the transfer of these 50000
workers took place without my knowledge, and the consequences of bringing
50000 workers from the West into Germany amounted to a catastrophe for
us on the Atlantic Wall. It meant that more than one-third of all the workers
engaged on the Atlantic Wall left because they, too, were afraid they might
have to go to Germany. That is why we rescinded the order as quickly as
possible, so that the French workers on the Atlantic Wall should have confidence
in us. This fact will show you that the French workers we had working for
the Organization Todt were not employed on a coercive basis, otherwise
they could not have left in such numbers when they realized that under
certain circumstances they, too, might be. taken to Germany. So these measures
taken with the 50000 workers from the Organization Todt in France were
only temporary and were revised later. It was one of those mistakes which
can happen if a minister gives a harsh directive and his subordinates begin
to carry it out by every means in their

MR. JUSTICE JACKSON: Are you familiar with Document EC-60, which reports
that the labor organization of Todt had to recruit its manpower by force?

SPEER: At the moment I cannot recollect it.

MR. JUSTICE JACKSON: I beg your pardon?

SPEER: At this moment I cannot recollect it. Could I see the document?

MR. JUSTICE JACKSON: Yes, if you would like to. I just remind you that
the evidence is to the contrary of your testimony on that subject.

Page 42, the paragraph which reads:

"Unfortunately the assignments for the Organization Todt on the basis
of Article 52 of the Hague Convention on Land Warfare have for some time
decreased considerably, because the larger part of the manpower allocated
does not turn up. Consequently further compulsory measures must be employed.
The prefect and the French labor exchanges co- operate quite loyally, it
is true, but they have not sufficient authority to carry out these measures."

SPEER: I think that I have perhaps not understood correctly. I do not
deny that a large number of the people working for the Organization Todt
in the West had been called up and came to their work because they had
been called up, but we had no means whatsoever of keeping them there by
force. That is what I wanted to say. So if they did not want to work, they
could leave again; and then they either joined the resistance movement
or went into hiding somewhere else.

MR. JUSTICE JACKSON: Very well. But this calling-up system was a system
of compulsion, was it not?

SPEER: It was the calling-up of French workers for service in the Reich
or in France. But here again I must add something. This report is dated
6/1943. In 10/1943 the whole of the Organization Todt was given the status
of a "blocked factory" and thereby received the advantages which other
blocked factories had. I explained that sufficiently yesterday. Because
of this, the Organization Todt had large offers of workers who went there
voluntarily, unless, of course, you see direct coercion in the pressure
put on them through the danger of their transfer to Germany, and which
led them to the Organization Todt or the blocked factories.

MR. JUSTICE JACKSON: Were they kept in labor camps?

SPEER: That is the custom in the case of such building work.

The building sites were far away from any villages, and so workers'
camps were set up to accommodate the German and foreign workers. But some
of them were also accommodated in villages, as far as it was possible to
accommodate them there. I do not think that on principle they were only
meant to be accommodated in camps, but I cannot tell you that for certain.

THE PRESIDENT: Has the document been introduced before?

MR. JUSTICE JACKSON: I was just going to give it to you. The document
from which I have quoted is United States Exhibit 892.

Now, leaving the question of the personal participation in this . .
.

THE PRESIDENT: Is it new, Mr. Justice Jackson?

MR. JUSTICE JACKSON: No, it has been in.

THE PRESIDENT: It has been in before?

MR. JUSTICE JACKSON: I am told that I am wrong about that, and that
it is new. 892 is a new number

[Turning to the defendant.] Leaving the part of your personal participation
in this program...

THE PRESIDENT: Could you tell us what the document is and where it comes
from? I see it is EC-60; so it must be captured. But ...

MR. JUSTICE JACKSON: It is one of the economic documents. It is a very
large document.

THE PRESIDENT: Could you tell us what it is or who signed it? It is
a
very long document, apparently, is it?

MR. JUSTICE JACKSON: It is a long document, and it is a report of the
OberfeldkommandantL-I-L-L-E is the name of the signer.

Now, coming to the question...

THE PRESIDENT: Let me look at the document, will you?

You see, Mr. Justice Jackson, my attention has been drawn to the point
that as far as the record is concerned, we have only this extract which
you read. We have not got the date, and we do not have the signature, if
any, on the document.

MR.JUSTICE JACKSON: I was merely refreshing his recollection to get
out the facts, and I was not really offering the document for its own sake.
I will go into more detail about it, if Your Honor wishes. There is a great
deal of irrelevant material in it.

THE PRESIDENT: If you do not want to offer it, then we need not bother
about it.

MR. JUSTICE JACKSON: A great part of it is not relevant.

THE PRESIDENT: Yes.

MR. JUSTICE JACKSON: The quotation is adequately verified.

THE PRESIDENT: In that case you may refer to it without the document
being used. Then we need not have the document identified as an exhibit.

MR. JUSTICE JACKSON: Turning to the defendant. Leaving the question
of your personal participation in these matters and coming to the questions
dealt with in the second part of your examination, I want to ask you about
your testimony concerning the proposal to denounce the Geneva Convention.

You testified yesterday that it was proposed to withdraw from the Geneva
Convention. Will you tell us who made those proposals?

SPEER: This proposal, as I already testified yesterday, came from Dr.
Goebbels. It was made after the air attack on Dresden, but before this,
from the autumn of 1944 on, Goebbels and Ley had often talked about intensifying
the war effort in every possible way, so that I had the impression that
Goebbels was using the attack on Dresden and the excitement it created
merely as an excuse to renounce the Geneva Convention.

MR. JUSTICE JACKSON: Now, was the proposal made at that time to resort
to poison gas warfare? SPEER: I was not able to make out from my own direct
observations whether gas warfare was to be started, but I knew from various
associates of Ley's and Goebbels' that they were discussing the question
of using our two new combat gases, Tabun and Sarin. They believed that
these gases would be of particular efficacy, and ; they did in fact produce
the most frightful results. We made these observations as early as the
autumn of 1944, when the situation had ! become critical and many people
were seriously worried about it.

MR. JUSTICE JACKSON: Now, will you tell us about these two gases and
about their production and their effects, their qualities, and the preparations
that were made for gas warfare?

SPEER: I cannot tell you that in detail. I am not enough of an expert.
All I know is that these two gases both had a quite extraordinary effect,
and that there was no respirator, and no protection against them that we
knew of. So the soldiers would have been unable to protect themselves against
this gas in any way. For the manufacture of this gas we had about three
factories, all of which were undamaged and which until 11/1944 were working
at full speed. When rumors reached us that gas might be used, I stopped
its production in 11/1944. I stopped it by the following means. I blocked
the so-called preliminary production, that is, the chemical supplies for
the making of gas, so that the gas production, as the Allied authorities
themselves ascertained, after the end of December or the beginning of January,
actually slowed down and finally came to a standstill. Beginning with a
letter which is still in existence and which I wrote to Hitler in 10/1944,
I tried through legal methods to obtain his permission to have these gas
factories stop their production. The reason I gave him was that on account
of air raids the preliminary products, primarily cyanide, were needed urgently
for other purposes. Hitler informed me that the gas production would have
to continue whatever happened, but I gave instructions for the preliminary
products not to be supplied any more.

MR. JUSTICE JACKSON: Can you identify others of the group that were
advocating gas warfare?

SPEER: In military circles there was certainly no one in favor of gas
warfare. All sensible Army people turned gas warfare down as being utterly
insane since, in view of your superiority in the air, it would not be long
before it would bring the most terrible catastrophe upon German cities,
which were completely unprotected.

MR. JUSTICE JACKSON: The group that did advocate it, however, consisted
of the political group around Hitler, didn't it?

SPEER: A certain circle of political people, certainly very limited.
It was mostly Ley, Goebbels and Bormann, always the same three, who by
every possible means wanted to increase the war effort; and a man like
Fegelein certainly belonged to a group like that too. Of Himmler I would
not be too sure, for at that time Himmler was a little out of favor with
Hitler because he allowed himself the luxury of directing an army group
without being qualified.

MR. JUSTICE JACKSON: Now, one of these gases was the gas which you proposed
to use on those who were proposing to use it on others, and I suppose your
motive was...

SPEER: I must say quite frankly that my reason for these plans was the
fear that under certain circumstances gas might be used, and the association
of ideas in using it myself led me to make the whole plan.

MR. JUSTICE JACKSON: And your reasons, I take it, were the same as the
military's, that is to say, it was certain Germany would get the worst
of it if Germany started that kind of warfare: That is what was worrying
the military, wasn't it?

SPEER: No, not only that. It was because at that stage of the war it
was perfectly clear that under no circumstances should any international
crimes be committed which could be held against the German people after
they had lost the war. That was what decided the issue.

MR. JUSTICE JACKSON: Now, what about the bombs, after the war was plainly
lost, aimed at England day after day; who favored that?

SPEER: You mean the rockets?

MR. JUSTICE JACKSON: Yes.

SPEER: From the point of view of their technical production the rockets
were a very expensive affair for us, and their effect compared to the cost
of their output was negligible. In consequence we had no particular interest
in developing the affair on a bigger scale. The person who kept urging
it was Himmler, in this case. He gave one Obergruppenfuhrer Kammler the
task of firing off these rockets over England. In Army circles they were
of the same opinion as I, namely, that the rockets were too expensive;
and in Air Force circles, the opinion was the same, since for the equivalent
of one rocket one could almost build a fighter. It is quite clear that
it would have been much better for us if we had not gone in for this nonsense.[=]

MR.JUSTICE JACKSON: Going back to the characteristics of this gas, was
one of the characteristics of this gas an exceedingly high temperature?
When it was exploded it created exceedingly high temperature, so that there
could be no defense against it?

SPEER: No, that is an error. Actually, ordinary gas evaporates at normal
atmospheric temperature. This gas would not evaporate until very high temperatures
were reached and such very high temperatures could only be produced by
an explosion; in other words, when the explosives detonated, a very high
temperature set in, as you know, and then the gas evaporated. The solid
substance turned into gas, but the effects had nothing to do with the high
temperature.

MR. JUSTICE JACKSON: Experiments were carried out with this gas, were
they not, to your knowledge?

SPEER: That I can tell you. Experiments must certainly have been carried
out with it.

MR. JUSTICE JACKSON: Who was in charge of the experimentations with
the gases?

SPEER: As far as I know it was the research and development department
of the OKH in the Army ordnance office. I cannot tell you for certain.

MR.JUSTICE JACKSON: And certain experiments were also conducted and
certain researches conducted in atomic energy, were they not?

SPEER: We had not got as far as that, unfortunately, because the finest
experts we had in atomic research had emigrated to America, and this had
thrown us back a great deal in our research, so that we still needed another
year or two in order to achieve any results in the splitting of the atom.

MR. JUSTICE JACKSON: The policy of driving people out who didn't agree
with Germany hadn't produced very good dividends, had it?

SPEER: Especially in this sphere it was a great disadvantage to us.

MR. JUSTICE JACKSON: Now, I have certain information, which was placed
in my hands, of an experiment which was carried out near Auschwitz and
I would like to ask you if you heard about it or knew about it. The purpose
of the experiment was to find a quick and complete way of destroying people
without the delay and trouble of shooting and gassing and burning, as it
had been carried out, and this is the experiment, as I am advised. A village,
a small village was provisionally erected, with temporary structures, and
in it approximately 20000 Jews were put. By means of this newly invented
weapon of destruction, these 20000 people were eradicated almost instantaneously,
and in such a way that there was no trace left of them; that it developed,
the explosive developed, temperatures of from 400 to 500 centigrade and
destroyed them without leaving any trace at all.

Do you know about that experiment?

SPEER: No, and I consider it utterly improbable. If we had had such
a weapon under preparation, I should have known about it. But we did not
have such a weapon. It is clear that in chemical warfare attempts were
made on both sides to carry out research on all the weapons one could think
of, because one did not know which party would start chemical warfare first.

MR. JUSTICE JACKSON: The reports, then, of a new and secret weapon were
exaggerated for the purpose of keeping the German people in the war?

SPEER: That was the case mostly during the last phase of the war. From
August, or rather June or 7/1944 on I very often went to the front. I visited
about 40 front-line divisions in their sectors and could not help seeing
that the troops, just like the German people, were given hopes about a
new weapon coming, new weapons and wonder-weapons which, without requiring
the use of soldiers, without military forces, would guarantee victory.
In this belief lies the secret why so many people in Germany offered their
lives, although common sense told them that the war was over. They believed
that within the near future this new weapon would arrive. I wrote to Hitler
about it and also tried in different speeches, even before Goebbels' propaganda
leaders, to work against this belief. Both Hitler and Goebbels told me,
however, that this was no propaganda of theirs but that it was a belief
which had grown up amongst the people. Only in the dock here in Nuremberg,
I was- told by Fritzsche that this propaganda was spread systematically
among the people through some channels or other, and that SS Standartenfuhrer
Berg was responsible for it. Many things have become clear to me since,
because this man Berg, as a representative of the Ministry of Propaganda,
had often taken part in meetings, in big sessions of my Ministry, as he
was writing articles about these sessions. There he heard of our future
plans and then used this knowledge to tell the people about them with more
imagination than truth.

MR. JUSTICE JACKSON: When did it become apparent that the war was lost?
I take it that your attitude was that you felt some responsibility for
getting the German people out of it with as little destruction as possible.
Is that a fair statement of your position?

SPEER: Yes, but I did not only have that feeling with regard to the
German people. I knew quite well that one should equally avoid destruction
taking place in the occupied territories. That was just as important to
me from a realistic point of view, for I said to myself that after the
war the responsibility for all these destructions would no longer fall
on us, but on the next German Government, and the coming German generations.

MR. JUSTICE JACKSON: Where you differed with the people who wanted to
continue the war to the bitter end, was that you wanted to see Germany
have a chance to restore her life. Is that not a fact? Whereas Hitler took
the position that if he couldn't survive, he didn't care whether Germany
survived or not?

SPEER: That is true, and I would never have had the courage to make
this statement before this Tribunal if I had not been able to prove it
with the help of some documents, because such a statement is so monstrous.
But the letter which I wrote to Hitler on 29 March, in which I confirmed
this, shows that he said so himself.

MR. JUSTICE JACKSON: Well, if I may comment, it was not a new idea to
us that that was his viewpoint. I think it was expressed in most of the
other countries that that was his viewpoint.

Now, were you present with Hitler at the time he received the telegram
from Goring, suggesting that Goring take over power?

SPEER: On 23 April I flew to Berlin in order to take leave of several
of my associates, andI should like to say this quite franklyafter all that
had happened, also in order to place myself at Hitler's disposal. Perhaps
this will sound strange here, but the conflicting feelings I had about
the action I wanted to take against him and about the way he had handled
things, still did not give me any clear grounds or any clear inner conviction
as to what my relations should be toward him, so I flew over to see him.
I did not know whether he knew of my plans, and I did not know whether
he would order me to remain in Berlin. Yet I felt that it was my duty not
to run away like a coward, but to stand up to him again. It was on that
day that Goring's telegram to Hitler arrived. This telegram was not to
Hitler, but from Goring to Ribbentrop; it was Bormann who submitted it
to him.

MR. JUSTICE JACKSON: Submitted it to Hitler?

SPEER: Yes, to Hitler.

MR. JUSTICE JACKSON: What did Hitler say on that occasion?

SPEER: Hitler was unusually excited about the contents of the telegram,
and said quite plainly what he thought about Goring. He said that he had
known for some time that Goring had failed, that he was corrupt, and that
he was a drug addict. I was extremely -shaken, because I felt that if the
head of the State had known this for such a long time, then it showed a
lack of responsibility on his part to leave such a man in office, when
the lives of countless people depended on him. It was typical of Hitler's
attitude towards the entire problem, however, that he followed his statement
up by saying: "But let him negotiate the capitulation all the same."

MR. JUSTICE JACKSON: Did he say why he was willing to let Goring negotiate
the capitulation?

SPEER: No. He said in an offhand manner: "It doesn't matter anyway who
does it." He expressed all his disregard for the German nation in the way
he said this.

MR. JUSTICE JACKSON: That is, his attitude was that there was nothing
left worth saving, so let Goring work it out. Is that a fair statement
of his position?

SPEER: That was my impression, yes.

MR. JUSTICE JACKSON: Now, this policy of driving Germany to destruction
after the war was lost had come to weigh on you to such a point that you
were a party to several plots, were you not, in an attempt to remove the
people who were responsible for the destruction, as you saw it, of your
country?

SPEER: Yes. But I want to add...

MR. JUSTICE JACKSON: There were more plots than you have told us about,
weren't there?

SPEER: During that time it was extremely easy to start a plot. One could
accost practically any man in the street and tell him what the situation
was, and then he would say: "This is insane"; and if he had any courage
he would place himself at your disposal. Unfortunately, I had no organization
behind me which I could call upon and give orders to, or designate who
should have done this or_that. That is why I had to depend on personal
conversations to contact all kinds of people. But I do want to say that
it was not as dangerous as it looks here because actually the unreasonable
people who were still left only amounted perhaps to a few dozen. The other
80 million were perfectly sensible as soon as they knew what it was all
about.[=]

MR. JUSTICE JACKSON: Perhaps you had a sense of responsibility for having
put the 80 million completely in the hands of the Fuhrer Principle. Did
that occur to you, or does it now, as you look back on it?

SPEER: May I have the question repeated, because I did not understand
its sense.

MR. JUSTICE JACKSON: You have 80 million sane and sensible people facing
destruction; you have a dozen people driving them on to destruction and
they are unable to stop it. And I ask if you have a feeling of responsibility
for having established the Fuhrer Principle, which Goring has so well described
for us, in Germany?

SPEER: I, personally, when I became Minister in 2/1942, placed myself
at the disposal of this Fuhrer Principle. But I admit, that in my organization
I soon saw that the Fuhrer Principle was full of tremendous mistakes, and
so I tried to weaken its effect. The terrible danger of the authoritarian
system, however, became really clear only at the moment when we were approaching
the end. It was then that one could see what the principle really meant,
namely, that every order should be carried out without criticism. Everything
that has become known during this Trial in the way of orders carried out
without any consideration, finally provedfor example the carrying-out of
the order to destroy the bridges in our own countryto be a mistake or a
consequence of this authoritarian system. The authoritarian systemor let
me put it like thisupon the collapse of the authoritarian system it became
clear what ,E tremendous dangers there are in a system of that kind, quite
apart from the personality of Hitler. The combination of Hitler and this
system, then, brought about these terrible catastrophes in the world.

MR. JUSTICE JACKSON: Well, nowHitler is dead; I assume you accept thatand
we ought to give the devil his due. Isn't it a fact that in the circle
around Hitler there was almost no one who would stand up and tell him that
the war was lost, except yourself?

SPEER: That is correct to a certain extent. Among the military leaders
there were many who, each in his own sphere, told Hitler quite clearly
what the situation was. Many commanders f of army groups, for instance,
made it clear to him how catastrophic developments were, and there were
often fierce arguments during the discussions on the situation. Men like
Guderian and Jodl, for instance, often talked openly about their sectors
in my presence, and Hitler could see quite well what the general situation
was like. But I never observed that those who were actually responsible
in the group around Hitler, ever went to him and said, "The war is lost."
Nor did I ever see these people who had responsibility endeavor to unite
in undertaking some joint step with Hitler. I did not attempt it for my
part either, except once or twice, because it would have been useless,
since at this stage, Hitler had so intimidated his closest associates that
they no longer had any wills of their own.

MR. JUSTICE JACKSON: Well, let us take the Number 2 man, who has told
us that he was in favor of fighting to the very finish.

Were you present at a conversation between Goring and General Galland,
in which Goring, in substance, forbade Galland to report the disaster that
was overtaking Germany?

SPEER: No; in that form, that is not correct. That was another conference.

MR. JUSTICE JACKSON: Well, tell us what there is about General Galland's
conversation with Goring, as far as you know it.

SPEER: It was at the Fuhrer's headquarters in East Prussia in front
of Goring's train. Galland had reported to Hitler that enemy fighter planes
were already escorting bomber squadrons as far as Liege and that it was
to be expected that in the future the bomber units would travel still farther
from their bases escorted by fighters. After a discussion with Hitler on
the military situation Goring upbraided Galland and told him with some
excitement that this could not possibly be true, that the fighters could
not go as far as Liege. He said that from his experience as an old fighter
pilot he knew this perfectly well. Thereupon Galland replied that the fighters
were being shot down, and were lying on the ground near Liege. Goring would
not believe this was true. Galland was an outspoken man who told Goring
his opinion quite clearly and refused to allow Goring's excitement to influence
him. Finally Goring, as Supreme Commander of the Air Force, expressly forbade
Galland to make any further reports on this matter. It was impossible,
he said, that enemy fighters could penetrate so deeply in the direction
of Germany, and so he ordered him to accept that as being true. I continued
to discuss the matter afterward with Galland and Galland was actually later
relieved by Goring of his duties as Commanding General of Fighters. Up
to this time Galland had been in charge of all the fighter units in Germany.
He was the general in charge of all the fighters within the High Command
of the Air Force.

MR. JUSTICE JACKSON: Well, let me ask you about your efforts in producing,
and see how much difficulty you were having. Krupp's was a big factor in
the German armament production, was it not?

MR. JUSTICE JACKSON: The biggest single unit, wouldn't you say?

SPEER: Yes, but notjust to the extent I said yesterday. It produced
few guns and armaments, but it was a big concern, one of the most respected
ones in the armament industry.

MR. JUSTICE JACKSON: But you had prevented, as far as possible, the
use of resources and manpower for the production of things that were not
useful for the war, is not that true?

SPEER: That is true.

MR. JUSTICE JACKSON: And the things which were being created, being
built in Krupp's, whether they were guns or other objects, were things
which were essential to carrying on the economy or to conducting the war?
That would be true, would it not?

SPEER: Generally speaking one can say that in the end every article
which in wartime is produced in the home country, whether it is a pair
of shoes for the workers, or clothing, or coal is, of courseis made to
assist in the war effort. That has nothing to do with the old conception,
which has long since died out, and which we find in the Geneva Prisoner
of War Convention.

MR. JUSTICE JACKSON: Well, at the moment I am not concerned with the
question of the application of the Geneva Convention. I want to ask you
some questions about your efforts to produce essential goods, whether they
were armament or not armament, and the conditions that this regime was
imposing upon labor and adding, as I think, to your problem of production.
I think you can give us some information about this. You were frequently
at the Krupp plant, were you not?

SPEER: I was at the Krupp plant five or six times.

MR. JUSTICE JACKSON: You had rather close information as to the progress
of production in the Krupp plant, as well as others?

SPEER: Yes, when I went to visit these plants, it was mostly in order
to see how we could do away with the consequences of air attacks. It was
always shortly after air raids, and so I got an idea of the production.
As I worked hard I knew a lot about these problems, right down to the details.

MR. JUSTICE JACKSON: Krupp also had several labor camps, did they not?

SPEER: Of course, Krupp had labor camps.

MR. JUSTICE JACKSON: Krupp was a very large user of both foreign labor
and prisoners of war?

SPEER: I cannot give the percentage, but no doubt Krupp did employ foreign
workers and prisoners of war.

MR. JUSTICE JACKSON: Well, I may say to you that we have investigated
the Krupp labor camps, and from Krupp's own charts it appears that in 1943
they had 39245 foreign workers and 11234 prisoners of war, and that this
steadily increased until in 9/1944 Krupp had 54990 foreign workers and
18902 prisoners of war.

Now, would that be somewhere near what you would expect from your knowledge
of the industry?

SPEER: I do not know the details. I do not know the figures of how many
workers Krupp employed in all. I am not familiar with them at the moment.
But I believe that the percentage of foreign workers at Krupp was about
the same as in other plants and in other armament concerns.

MR. JUSTICE JACKSON: And what would you say that percentage was?

SPEER: That varied a great deal. The old established industries which
had their old regular personnel had a much lower percentage of foreign
workers than the new industries which had just grown up and which had no
old regular personnel. The reason for this was that the young age groups
were drafted into the Armed Forces and therefore the concerns which had
a personnel of older workers still retained a large percentage of the older
workers. Therefore the percentage of foreign workers in Army armaments,
if you take it as a whole and as one of the older industries, was lower
than the percentage of foreign workers in air armaments, because that was
a completely new industry which had no old regular personnel.

***

MR. JUSTICE JACKSON: Now, the foreign workers who were assigned to Krupplet
us use Krupp as an examplewere housed in labor camps and under guard, were
they not?

SPEER: I do not believe that they were under guard, but I cannot say.
I do not want to dodge giving information here, but I had no time to worry
about such things on my visits. The things I was concerned about when I
went to a factory were in an entirely different sphere. In all my activities
as Armament Minister I never once visited a labor camp, and cannot, therefore,
give any information about them.

MR.JUSTICE JACKSON: Well now, I am going to give you some information
about the labor camp at Krupp's, and then I am going to ask you some questions
about it. And I am not attempting to say that you were personally responsible
for these conditions. I merely give you the indications as to what the
regime was doing and I am going to ask you certain questions as to the
effect of this sort of thing on your work of production.

Are you familiar with Document D-288, which is United States Exhibit
202, the affidavit of Dr. Jager, who was later brought here as a witness?

SPEER: Yes, but I consider that somewhat exaggerated.

MR.JUSTICE JACKSON: You don't accept that?

MR. JUSTICE JACKSON: Well, you have no personal knowledge of the conditions.
What is the basis of your information that Dr. Jager's statement is exaggerated?

SPEER: If such conditions had existed, I should probably have heard
of them, since when I visited plants the head of the plant naturally came
to me with his biggest troubles. These troubles occurred primarily after
air raids when, for example, both the German workers and foreign workers
had no longer any proper shelter. This state of affairs was then described
to me, so that I know that what is stated in the Jager affidavit cannot
have been a permanent condition. It can only have been a condition caused
temporarily by air raids, for a week or a fortnight, and which was improved
later on. It is clear that after a severe air raid on a city all the sanitary
installations, the water supply, gas supply, electricity, and so on, were
out of order and severely damaged, so that temporarily there were very
difficult conditions.

MR. JUSTICE JACKSON: I remind you that Dr. Jager's affidavit relates
to the time of 10/1942, and that he was a witness here. And, of course,
you are familiar with his testimony.

MR. JUSTICE JACKSON: Well now, I call your attention to a new document,
which is D-361, and would become United States Exhibit 893, a document
signed by the office chief of the locomotive construction works, describing
conditions of his labor supply, foreign labor.

And I am not suggestingI repeat I am not suggesting that this was your
responsibility. I am suggesting it is the responsibility of the regime.
I should like to read this despite its considerable length. This is dated
at the boilermaking shop, 2/25/1942, addressed to Hupe by way of Winters
and Schmidt.

"I received the enclosed letter of the 18th of this month from the German
Labor Front, sent to my private address, inviting me to the Office of the
German Labor Front. I tried to settle the business, which I did not know
about, by telephone. The answer from the German Labor Front was that the
matter was very important and called for my personal appearance. Thereupon
I asked Herr Jungerich of the Department for Social Labor Matters whether
I had to go. He answered, 'You probably do not have to, but it would be
better if you went.' About 9:50 I went to Room 20 at the place indicated
and met Herr Prior.

"The following provided the subject of this conversation, which Herr
Prior carried on in a very excited manner, and which lasted about half
an hour:

"On the 16th, 23 Russian prisoners of war were assigned to Number 23
Boiler Shop. The people came in the morning without bread and tools. During
both breaks the prisoners of war crept up to the German workers and begged
for bread, pitifully pointing out their hunger. (For lunch on the first
day the factory was able to distribute among the Russians rations which
remained over from French POW's. In order to alleviate these conditions,
I went to the Weidkamp kitchen on the 17th, on instructions from Herr Theile,
and talked to the head of the kitchen, Fraulein Block, about the provision
of the midday meal. Fraulein Block promised me the food immediately, and
also lent me the 22 sets of eating utensils which I asked for. At the same
time I asked Fraulein Block to give any food left over by the 800 Dutchmen
messing there to our Russian POW's at noon until further notice. Fraulein
Block promised to do this too, and the following noon she sent down a container
of milk soup as an extra. The following noon the ration was short in quantity.
Since a few Russians had collapsed already, I telephoned Fraulein Block
and asked for an increase in the food, as the special ration had ceased
from the second day onwards. As my telephone conversation was unsuccessful,
I again visited Fraulein Block personally. Fraulein Block refused in a
very abrupt manner to give any further special ration.

"Now, regarding the discussion in detail, Herr Prior, two other gentlemen
of the DAF and Fraulein Block, head of the Weidkamp kitchen, were present
in the room. Herr Prior commenced and accused me, gesticulating, and in
a very insulting manner, of having taken the part of the Bolsheviks in
a marked way. He referred to the law paragraphs of the Reich Government
which spoke against it. I was unfortunately not clear about the legal position,
otherwise I would have left the conference room immediately. I then tried
to make it clear to Herr Prior, with special emphasis, that the Russian
POW's were assigned to us as workers and not as Bolsheviks; the people
were starved and not in a position to perform the heavy work with us in
the boiler shop which they were supposed to do; sick people are a dead
weight to us and not a help to production. To this remark Herr Prior stated
that if one was no good, then another was; that the Bolsheviks were a soulless
people; and if 100000 of them died, another 100000 would replace them.
On my remarking that with such a coming and going we would not attain our
goal, namely the delivery of locomotives to the Reichsbahn, who were continually
cutting down the time limit, Herr Prior said, 'Deliveries are only of secondary
importance here.'

"My attempts to get Herr Prior to understand our economic needs were
not successful. In closing, I can only say that as a German I know our
relations to the Russian prisoners of war exactly, and in this case I acted
only on behalf of my superiors and with the view to the increase in production
which is demanded from us."

It is signed, "Sohling, Office Chief, Locomotive Construction Works."

And there is added this letter as a part of the communication, signed
by Theile:

"I have to add the following to the above letter:

"After the Russian POW's had been assigned to us on the 16th of this
month by labor supply, I got into touch with Dr. Lehmann immediately about
their food. I learned from him that the prisoners received 300 gr. of bread
each between 0400 and 0500 hours. I pointed out that it was impossible
to last until 1800 hours on this ration of bread, whereupon Dr. Lehmann
said that the Russians must not be allowed to get used to western European
feeding. I replied that the POW's could not do the work required of them
in the boiler

shop on that food, and that it was not practical for us to have these
people in the works any longer under such conditions. At the same time
I demanded that if the Russians continued to be employed, they should be
given a hot midday meal, and that if possible the bread ration should be
split so that one-half was distributed early in the morning and the second
half during our breakfast break. My suggestion has already been carried
out by us with the French POW's and has proved to be very practicable and
good.

"Unfortunately, however, Dr. Lehmann took no notice of my suggestion,
and on this account I naturally had to take matters into my own hands and
therefore told Herr Sohling to get the feeding of the Russian POW's organized
on exactly the same lines as for the French POW's, so that the Russians
could as soon as possible carry out the work they were supposed to do.
For the whole thing concerns an increase in production such as is demanded
from us by the Minister of munitions and armaments and by the DAF."

Now, I ask you, in the first place, if the position of the chief of
the locomotive construction works was not entirely a necessary position
in the interests of production?

SPEER: It is clear that a worker who has not enough food cannot achieve
a good work output. I already said yesterday that every head of a plant,
and I too at the top, was naturally interested in having well-fed and satisfied
workers, because badly fed, dissatisfied workers make more mistakes and
produce poor results.

I should like to comment on this document. The document is dated 2/25/1942.
At that time there were official instructions that the Russian workers
who came to the Reich should be treated worse than the western prisoners
of war and the western workers. I learned of this through complaints from
the heads of concerns. In my document book, there is a Fuhrer protocol
which dates from the middle of 3/1942that is, 3 or 4 weeks after this documentin
which I called Hitler's attention to the fact that the feeding both of
Russian prisoners of war and of Russian workers was absolutely insufficient
and that they would have to be given an adequate diet, and that moreover
the Russian workers were being kept behind barbed wire like prisoners of
war and that that would have to be stopped also. The protocol shows that
in both cases I succeeded in getting Hitler to agree that conditions should
be changed and they were changed.

I must say furthermore that it was really to Sauckel's credit that he
fought against a mountain of stupidity and did everything so that foreign
workers and prisoners of war should be treated better and receive decent
food.[=]

MR. JUSTICE JACKSON: Well, we will go on with the conditions later.
Because I am going to ask you, if you are not responsible and Sauckel is
not responsible, v.ho is responsible for these conditions, and you can
keep it in mind that is the question that we are coming up to here.

I will show you a new document, which is a statement, D-398, which would
be Exhibit USA 894-A, taken by the British-American team in the investigation
of this work camp at Krupp's.

Well, D-321. I can use that just as well. We will use Document D-321,
which becomes 893.

THE PRESIDENT: 894 was the last number you gaze us. What number is this
document that you are now offering?

MR. JUSTICE JACKSON: 398 was 894. 321 will be 895.

Now, this relates to thethis is an employee of the Reich Railways. None
of our investigation, I may say, is based upon the statements of the prisoners
themselves.

"I, the undersigned, Adam Schmidt, employed as Betriebswart on the Essen-West
Railway Station and residing . . . state voluntarily and on oath:

"I have been employed by the Reich Railways since 1918 and have been
at Essen-West Station since 1935. In the middle of 1941 the first workers
arrived from Poland, Galicia, and the Polish Ukraine. They came to Essen
in trucks in which potatoes, building materials and also cattle had been
transported, and were brought to perform work at Krupp's. The trucks were
jammed full with people. My personal view was that it was inhuman to transport
people in such a manner. The people were packed closely together and they
had no room for free movement. The Krupp overseers laid special value on
the speed with which the slave workers got in and out of the trucks. It
was enraging for every decent German who had to watch this to see how the
people were beaten and kicked and generally maltreated in a brutal manner.
In the very beginning when the first transport arrived we could see how
inhumanly these people were treated. Every truck was so overfilled that
it was incredible that such a number of people could be jammed into one.
I could see with my own eyes that sick people who could scarcely walk they
were mostly people with foot trouble, or with injuries, and people with
internal trouble) were nevertheless taken to work. One could see that it
was sometimes difficult for them to move. The same can be said of the Eastern
Workers and POW's who came to Essen in.the middle of 1942."

He then describes their clothing and their food. In the interest of
time, I will not attempt to read the entire thing.

Do you consider that that, too, is an exaggerated statement?

SPEER: When the workers came to Germany from the East, their clothing
was no doubt bad, but I know from Sauckel that while he was in office a
lot was done to get them better clothes, and in Germany many of the Russian
workers were brought to a considerably better condition than they had previously
been in in Russia. The Russian workers were quite satisfied in Germany.
If they arrived here in rags, that does not mean that that was our fault.
We could not use ragged workers with poor shoes in our industry, so conditions
were improved.

MR. JUSTICE JACKSON: Well, now, I would like to call your attention
to D-398.

THE PRESIDENT: Well, before you pass from that, what do you say about
the conditions of the transports? The question you were asked was whether
this was an exaggerated account. You have not answered that except in reference
to clothing.

SPEER: Mr. President, I cannot give any information about this transport
matter. I received no reports about it.

MR. JUSTICE JACKSON: Well, I will ask you about Exhibit 398, which becomes
USA-894. I mean Document 398, which becomes Exhibit 894, a statement by
Homer, living in Essen:

"From 4/1943 I worked with Lowenkamp every day in Panzer Shop 4. Lowenkamp
was brutal to the foreigners. He confiscated food which belonged to the
POW's and took it home. Every day he maltreated Eastern Workers, Russian
POW's, French, Italian, and other foreign civilians. He had a steel cabinet
built which was so small that one could hardly stand in it. He locked up
foreigners in the box, women too, for 48 hours at a time without giving
the people food.

"They were not released even to relieve nature. It was forbidden for
other people, too, to give any help to the persons locked in, or to release
them. While clearing a concealed store he fired on escaping Russian civilians
without hitting any of them.

"One day, while distributing food, I saw how he hit a French civilian
in the face with a ladle and made his face bleed. Further, he delivered
Russian girls without bothering about the children afterwards. There was
never any milk for them so the Russians had to nourish the children with
sugar water. When Lowenkamp was arrested he wrote two letters and sent
them to me through his wife. He tried to make out that he never beat people."

There is a good deal more of this, but I will not bother to put it into
the record.

Is it your view that that is exaggerated?

SPEER: I consider this affidavit a lie. I would say that among German
people such things do not exist, and if such individual cases occurred
they were punished. It is not possible to drag the German people in the
dirt in such a way. The heads of concerns were decent people too, and took
an interest in their workers. If the head of the Krupp plant heard about
such things, he certainly took steps immediately.

MR. JUSTICE JACKSON: Well, what about the steel boxes? The steel box
couldn't have been built? Or don't you believe the steelbox story?

SPEER: No, I do not believe it; I mean I do not believe it is true.
After the collapse in 1945 a lot of affidavits were certainly drawn up
which do not fully correspond to the truth. That is not your fault. It
is the fault ofafter a defeat, it is quite possible that people F lend
themselves to things like that.

MR. JUSTICE JACKSON: Well, I would like to have you examine Document
258, and I attach importance to this as establishing the SS as being the
guards:

"The camp inmates were mostly Jewish women and girls from Hungary and
Romania. The camp inmates were brought to Essen at the beginning of 1944
and were put to work at Krupp's. The accommodation and feeding of the camp
prisoners was beneath all dignity. At first the prisoners were accommodated
in simple wooden huts. These huts were burned down during an air raid and
from that time on the prisoners had to sleep in a damp cellar. Their beds
were made on the floor and consisted of a straw-filled sack and two blankets.
In most cases it was not possible for the prisoners to wash themselves
daily, as there was no water. There was no possibility of having a bath.
I could often observe from the Krupp factory, during the lunch break, how
the prisoners boiled their under-clothing in an old bucket or container
over a wood fire, and cleaned themselves. An air-raid trench served as
shelter, while the SS guards went to the Humboldt shelter, which was bombproof.
Reveille was at 5 a. m. There was no coffee or any food served in the morning.
They marched off to the factory at 5.15 a. m. They marched for three-quarters
of an hour to the factory, poorly clothed and badly shod, some without
shoes, and covered with a blanket, in rain or snow.

Work began at 6 a. m. The lunch break was from 12 to 12.30. Only during
the break was it at all possible for the prisoners to cook something for
themselves from potato peelings and other garbage. The daily working period
was one of 10 or 11 hours. Although the prisoners were completely undernourished,
their work was very heavy physically. The prisoners were often maltreated
at their work benches by Nazi overseers and female SS guards. At 5 or 6
in the afternoon they were marched back to camp. The accompanying guards
consisted of female SS who, in spite of protests from the civil population,
often maltreated the prisoners on the way back with kicks, blows, and scarcely
repeatable words. It often happened that individual women or girls had
to be carried back to the camp by their comrades owing to exhaustion. At
6 or 7 p.m. these exhausted people arrived back in camp. Then the real
meal was distributed. This consisted of cabbage soup. This was followed
by the evening meal of water soup and a piece of bread which was for the
following day. Occasionally the food on Sundays was better. As long as
it existed there was never any inspection of the camp by the firm of Krupp.
On 3/13/1945 the camp prisoners were brought to Buchenwald Concentration
Camp, from there some were sent to work. The camp commandant was SS Oberscharfuhrer
Rick. His present whereabouts is unknown."

The rest of it doesn't matter. In your estimation that, I suppose, is
also an exaggeration?

SPEER: From the document...

DR. FLACHSNER: Mr. President . . .

THE PRESIDENT: May I hear the answer. I thought the defendant said something.

DR. FLACHSNER: May I call the attention of the Court to the document
itself, of which I have only a copy? It is headed "Sworn on oath before
a military court," and there is an ordinary signature under it. It does
not say that it is an affidavit or a statement in lieu of oath, or any
other such thing, it says only, "Further inquiries must be made," and it
is signed by Hubert Karden. That is apparently the name of the man who
was making the statement. Then there is another signature, "Kriminalassistent
Z. Pr." That is a police official who is on probation and who may later
have the chance of becoming a candidate in the criminal service. He has
signed it. Then there is another signature, "C. E. Long, Major, President."
There is not a word in this document to the effect that any of these three
people want to vouch for the contents of this as an affidavit. I do not
believe this document can be used as an affidavit in that sense.

THE PRESIDENT: Yes, Mr. Justice Jackson? Do you wish to say anything?

MR. JUSTICE JACKSON: Ithe document shows for itself. I am notas I have
pointed out to this witness, I am giving him the result of an investigation.
I am not prosecuting him with personal responsibility for these conditions.
I intend to ask him some questions about responsibility for conditions
in the camp.

THE PRESIDENT: Well, there is a statement at the top of the copy that
I have got, "Sworn on oath before a military court."

MR. JUSTICE JACKSON: Yes, they were taken in Essen, in this investigation.
And of course, if I were charging this particular defendant with the responsibility
there might be some argument about it. They come under the headthey clearly
come under the head of the Charter, which authorizes the receipt here of
proceedings of other courts.

THE PRESIDENT: Have you got the original document here?

MR. JUSTICE JACKSON: Yes.

[A document was submitted to the Tribunal.]

THE PRESIDENT: The Tribunal sees no objection to the document being
used in cross-examination.

Did you give it an exhibit number?

MR. JUSTICE JACKSON: I should have; it is USA-896.

THE PRESIDENT: Yes.

MR. JUSTICE JACKSON: [Turning to the defendant.] I now want to call
your attention to Exhibit Number 382.

SPEER: I wanted to comment on the document.

THE PRESIDENT: Mr. Justice Jackson, there are some photographs which
have been put before us. Are they identified and do they form part of an
exhibit?

MR. JUSTICE JACKSON: They form part of the exhibit which I am now offering.

THE PRESIDENT: I see.

MR. JUSTICE JACKSON: But the witness desires to comment on the last
document, and I will listen to that before we go ahead.

SPEER: First I should like to say, as you have so often mentioned my
non-responsibility, that if in general these conditions had been true,
on the basis of my statement yesterday I should consider myself responsible.
I refuse to evade responsibility. But the conditions were not what they
are said to have been here. There are only individual cases which are quoted.

As for this document I should only like to say from what I have seen
of it that this seems to concern a concentration camp, one of the small
concentration camps near the factories. The factories could not inspect
these camps. That is why the sentence is quite true where it says that
no factory representative ever saw the camp. The fact that there were SS
guards also shows that it was a concentration camp.

If the question which you asked me before, as to whether the labor camps
were guardedthose for foreign workersif that refers to this document, then
your conclusion was wrong. For as far as I know, the other labor camps
were not guarded by SS or by any other organizations.

My position is such that I feel it is my duty to protect the heads of
plants from any injustice which might be done them. The head of a plant
could not bother about the conditions in such a camp. I cannot say whether
conditions were as described in this camp. We have seen so much material
on conditions in concentration camps during the Trial.

MR. JUSTICE JACKSON: Now I will ask to have you shown Exhibit Number
D-382I should say Document D-382which would be United States Exhibit 897.
Now that is the statement of several persons as to one of those steel boxes
which stood in the foreign workers' camp in the grounds of Number 4 Armor
Shop, and of those in the Russian camp. I do not know that it is necessary
to read the complete descriptions.

Is that merely an individual instance, or what is your view of that
circumstance?

SPEER: What is pictured here is quite a normal locker as was used in
every factory. These photographs have absolutely no value as evidence.

MR. JUSTICE JACKSON: Very well. I will ask to have you shown Exhibit
D-230. Together with D-230 is an interoffice record of the steel switches,
and the steel switches which have been found in the camp will be shown
to you. Eighty were distributed, according to the reports.

SPEER: Shall I comment on this?

MR. JUSTICE JACKSON: If you wish.

SPEER: Yes. Those are nothing but replacements for rubber truncheons.
We had no rubber; and for that reason, the guards probably had something
like this.

MR. JUSTICE JACKSON: That is the same inference that I drew from the
document.

SPEER: Yes, but the guards did not immediately use these steel switches
any more than your police use their rubber truncheons. But they had to
have something in their hands. It is the same thing all over the world.

MR. JUSTICE JACKSON: Well, we won't argue that point.

SPEER: I am not an expert. I only assume that that is the case. I cannot
testify on oath that that was the case. That was only an argument.

THE PRESIDENT: Did you give a number to that?

MR. JUSTICE JACKSON: 898, Your Honor.

Now, 899 would be our Document D-283, which is a 1943 report from the
Krupp hospitals taken from the files of Krupp's.

"The subject:

"Cases of Deaths of Eastern Workers.

"Fifty-four Eastern Workers have died in the hospital in Lazarettstrasse,
4 of them as a result of external causes and 50 as a result of illness.

"The causes of death in the case of these 50 Eastern Workers who died
of illnesses were the following: Tuberculosis, 36 (including 2 women);
malnutrition, 2; internal hemorrhage, 1; disease of the bowels, 2; typhoid
fever, 1 (female); pneumonia, 3; appendicitis, 1 (female); liver trouble,
1; abscess of the brain, 1. This list therefore shows that four-fifths
died of tuberculosis and malnutrition."

Now, did you have any reports from time to time as to the health conditions
of the labor which was engaged in your production program?

SPEER: First I should like to comment on the document. The document
does not show the total number of the workers to which the number of deaths
refers, so that one cannot say whether that is an unnaturally high proportion
of illness. At a session of the Central Planning Board which I read here
again, I observed i it was said that among the Russian workers there was
a high rate of tuberculosis. I do not know whether you mean that. That
was a remark which Weiger made to me. But presumably through the health
offices we tried to alleviate these conditions.

MR.JUSTICE JACKSON: There was an abnormally high rate of deaths from
tuberculosis; there is no doubt about that, is there?

SPEER: I do not know whether that was an abnormal death rate. But there
was an abnormally high rate of tuberculosis at times.

MR. JUSTICE JACKSON: Well, the exhibit does not show whether the death
rate itself was abnormally high, but it shows an abnormal proportion of
deaths from tuberculosis among the total deaths, does it not? Eighty percent
deaths from tuberculosis is a very high incidence of tuberculosis, is it
not?

SPEER: That may be. I cannot say from my own knowledge.

MR. JUSTICE JACKSON: Now I would like to have you shown . . .

THE PRESIDENT: Did you give that a number? That would be 899, would
it not?

MR. JUSTICE JACKSON: 899, Your Honor.

Now, let me ask you to be shown Document D-335. This is a report from
the files of Krupp, dated at Essen on 6/12/1944, directed to the "Gau Camp
Physician, Herr Dr. Jager," and signed by Stinnesbeck:

"In the middle of May I took over the medical supervision of the POW
Camp 1420 in the Norggerathstrasse. The camp contains 644 French POW's.

"During the air raid on 27 April of this year the camp was largely destroyed
and at the moment conditions are intolerable.

"315 prisoners are still accommodated in the camp. 170 of these are
no longer in huts, but in the tunnel in Grunerstrasse on the Essen-Mulheim
railway line. This tunnel is damp and is not suitable for continued accommodation
of human beings. The rest of the prisoners are accommodated in 10 different
factories in Krupp's works.

"Medical attention is given by a French military doctor who takes great
pains with his fellow countrymen. Sick people from Krupp's factories must
be brought to the sick parade too. This parade is held in the lavatory
of a burned-out public house outside the camp. The sleeping accommodations
of the four French medical orderlies is in what was the urinal room. There
is a double tier wooden bed available for sick bay patients. In general,
treatment takes place in the open. In rainy weather it has to be held in
this small room. These are insufferable conditions! There are no chairs,
tables, cupboards, or water. The keeping of a register of sick is impossible.

"Bandages and medical supplies are very scarce, although people badly
hurt in the works are often brought here for first aid and have to be bandaged
before being taken to the hospital. There are many strong complaints about
food, too, which the guard personnel confirm as being justified.

"Illness and less manpower must be reckoned with under these circumstances.

"The construction of huts for the accommodation of the prisoners and
the building of sick quarters for the proper treatment of the sick persons
is urgently necessary.

"Please take the necessary steps.

"(Signed) Stinnesbeck."

SPEER: That is a document which shows what conditions can e after severe
air raids. The conditions were the same in these cases for Germans and
foreign workers. There were no beds, no cupboards, and so forth. That was
because the camp in which these things had been provided had been burned
down. That the food supply was often inadequate in the Ruhr district during
this period was due to the fact that attacks from the air were centered
on communication lines, so that food transports could not be brought into
the Ruhr to the necessary extent. These were temporary conditions which
we were able to improve when the air raids ceased for a time. When conditions
became even worse after September or October of 1944, or rather after November
of 1944, we made every effort to give food supplies the priority for the
first time over armament needs, so that in view of these difficulties the
workers would be fed first of all, while armaments had to stand back somewhat.

MR JUSTICE JACKSON: Well, then you did make it your business to get
food and to see to the conditions of these workers? Do I understand that
you did it, that you took steps?

SPEER: It is true that I did so, and I am glad that I did, even if I
am to be reproached for it. For it is a universal human obligation when
one hears of such conditions to try to alleviate them, even if it is somebody
else's responsibility. But the witness Riecke testified here that the whole
of the food question was under the direction of the Food Ministry.

MR. JUSTICE JACKSON: And it was an essential part of production, was
it not, to keep workers in proper condition to produce? That is elementary,
is it not?

SPEER: No. That is wrongly formulated.

MR. JUSTICE JACKSON: Well, you formulate it for me as to what the relation
is between the nourishment of workers and the amount of production produced.

SPEER: I said yesterday that the responsibility for labor conditions
was divided up between the Food Ministry, the Health Office in the Reich
Ministry of the Interior, the Labor Trustee in the office of the Plenipotentiary
General for the Allocation of Labor, and J so on. There was no comprehensive
authority in my hands. In the Reich, because of the way in which our state
machine was built up, we lacked a comprehensive agency in the form of a
Reich Chancellor, who would have gathered all these departments together
and held joint discussions. But I, as the man responsible for production,
had no responsibility in these matters. However, when I heard complaints
from factory heads or from my deputies, I did everything to remove the
cause of the complaints.

MR. JUSTICE JACKSON: The Krupp works . . .

THE PRESIDENT: Shall we break off now?

MR. JUSTICE JACKSON: Any time you say, Sir.

THE PRESIDENT: The Tribunal wish to hear from defendants' counsel what
arrangements they have found it possible to make -with reference to the
apportionment of time for their speeches.

DR. NELTE: I should like first of all to point out that the defendants'
counsel, with whom the Tribunal discussed the question of final defense
speeches during an earlier closed session, did not inform the other defendants'
counsel, since they were under the impression that the Tribunal would not
impose any restrictions on the Defense in this respect. I personally, when
I raised my objections, had no knowledge of this discussion, as my colleagues
who conferred with you earlier have authorized me to explain.

On the suggestion of the Tribunal, counsel for the individual defendants
have discussed the decision announced in the session of 6/13/1946, and
I am now submitting to the Tribunal the outcome of the discussion; in doing
so, however, I shall have to make certain qualifications, since some of
my colleagues are either not present or differ in their opinion on the
apportionment of time.

The defendants' counsel are of the opinion that only the conscientious
judgment of each counsel can determine the form and length of the final
defense pleas in this unusual Trial, notwithstanding the generally recognized
right of the Tribunal, as part of its responsibility for guiding the proceedings,
to prevent a possible

misuse of the freedom of speech. They also believe that, in view 1 of
this fundamental consideration and in view of the usual practice

-of international courts, the Tribunal will understand and approve that
the defendants' counsel voice their objection to a preventive restriction
of the freedom of speech, for a misuse on their part must not simply be
taken as a foregone conclusion. This fundamental attitude is, of course,
in accord with the readiness of the Defense to comply with the directives
and the wishes of the Tribunal as far as is reconcilable with a proper
conception of the defense in each

-case. Under this aspect the individual defendants' counsel have been
asked to make their own estimates of the probable duration of their final
pleas. The result of these estimates shows that, despite the limitations
counsel have imposed upon themselves, and with due respect to the wishes
of the High Tribunal, a total duration of approximately 20 full days in
court is required by the Defense.

THE PRESIDENT: Dr. Nelte, the Tribunal asked Defense Counsel for an
apportionment of the 14 days between them.

DR. NELTE: I believe, Mr. President, my statement makes clear that it
appears impossible to accept that principle. If the Tribunal consider these
14 full days as indisputable, then the entire Defense will submit to that
decision. But so far as I know, it will be quite impossible, under such
circumstances, to obtain agreement among Defense Counsel, and considerable
danger therefore exists that counsel who make their pleas later will be
under pressure of time.

THE PRESIDENT: Yes, I think the Tribunal probably fully understands
that you think 14 daysyou and your brethren consider that 14 days is too
shortbut, as I say, what the Tribunal asked for was an apportionment of
the time, and there is nothing in what you have said to indicate that you
have made any apportionment at all, either of the 14 days or of the 20
days which you propose.

DR. NELTE: The period of 20 days was arrived at when each defendant's
counsel had stated the presumed duration of his speech. It would, therefore,
be perfectly possible to say that if the Tribunal would approve the duration
of 20 days, then we could state our solution for the length of the individual
speeches. But it is impossible, in practice, to apportion the time, if
the total number of days is only 14. You can rest assured, Mr.President,
that we have all gone into the question conscientiously and that we have
also reflected on the manner in which individual subjects can be divided
among individual defendants' counsel; but the total number of about 20
days appears to us, without wanting to quote a maximum or minimum figure,
to be absolutely essential for an apportionment. It is perfectly possible,
Mr. President, that in the course of the speeches . . .

THE PRESIDENT: Dr. Nelte, as I have indicated to you, what the Tribunal
wanted to know was the apportionment, and presumably you have some apportionment
which adds up to the 20 days which you say is required; and the Tribunal
would like, if you have such an apportionment, that you should let them
see the apportionment, or if you have no such apportionment, then they
would wish to hear from each individual counsel how long he thinks he is
going to take. If you have got a list, it seems to the Tribunal that you
could hand it in.

DR. NELTE: The figures are available and they will be handed to the
Tribunal, but some of my colleagues have said that their estimates are
only valid on the assumption that no more than a specific number of days
was to be granted. That is the point of view of which I said earlier that
it differed in some respect. But we all thought that the decision of the
Tribunal was only a suggestion, and not a maximum to be apportioned. I
hope, Mr. President, that your words now are also to be understood in that
way, and that the Tribunal will still consider whether the proposed period
of 14 days could not be extended to correspond with the time which we consider
necessary.

THE PRESIDENT: What the Tribunal wants is an apportionment of the time
as between the various counsel. That is what they asked for and that is
what they want; and either we would ask you to give it to us in writing
now, or we would ask you, each one of you, to state how long you anticipate
you will take in your speech.

DR. NELTE: I think that I may speak on behalf of my colleagues and say
that we shall submit our estimates to the Tribunal in writing.

THE PRESIDENT: Dr. Nelte, the Tribunal feels that it would like to have
the apportionment now. It gave notice before, yesterday I think it was,
that they were wishing to hear defendants' counsel upon the question of
the apportionment this afternoon at 2 o'clock; and they would, therefore,
like to have that apportionment now.

DR. NELTE: In that case, I can only ask that the Tribunal hear each
individual counsel, since naturally I cannot say from memory how each made
his estimate.

THE PRESIDENT: You could have had it written down; but if k you have
not got it written down, no doubt you cannot remember. But perhaps you
had better give us what you would take.

DR. OTTO PANNENBECKER (Counsel for Defendant Frick): For Frick, 5 hours.
I remember from the list that Dr. Bergold wants 3 hours for Bormann. Dr.
Bergold is not present, but I remember that the list said 3 hours.

DR. VON LUDINGHAUSEN: For myself, Mr. President, 8 hours. For Professor
Jahrreiss, who before the final pleas will deal with a technical subject,
4 hours.

THE PRESIDENT: What will Professor Jahrreiss speak about

DR.VON LUDINGHAUSEN: About a subject approved by the Tribunal, namely
the general question of international law.

DR. SEIDL: The defense counsel for the Defendant Rosenberg said that
he would require 8 hours.

DR. FRITZ: Mr. President, I would ask the Tribunal to take into consideration
that the case of Fritzsche has not yet been presented and that therefore
I cannot give exact information; but I estimate approximately 4 hours.

THE PRESIDENT: Now, Dr. Nelte, the Tribunal would like to know first
of all whether counsel propose to write down and then read their speeches.

DR. NELTE: As far as I have been informed, all defense counsel will
write down their speeches before delivery. Whether they will actually read
every word of the text, or whether they will read parts of it and submit
other parts, is not yet certain.

THE PRESIDENT: Have they considered whether they will submit them for
translation, because, as the Tribunal has already pointed out, it would
be much more convenient for the members of the Tribunal who do not read
German to have a translation before them. It would not only greatly assist
the Tribunal, but the defendants themselves if they do that.

DR. NELTE: This question has not yet been settled. We discussed it,
but have so far not come to a final conclusion. We think that the short
time now available may perhaps make it impossible to translate the manuscripts
into all four languages.

THE PRESIDENT: The defendants' counsel, of course, understand that the
speeches, if they are submitted for translation, will not be communicated
to anybody until the speech is actually made. So they will not be given
beforehand either to the Tribunal or the Prosecution or anything of that
sort, so that the speech will remain entirely private until it is made.
And the second thing is that, of course, a great number of the speeches
will be delayed by the counsel who precede them and, therefore, there will
be very considerable time during either the 14 days or some longer period,
if such a longer period is given, which will enable the speeches to be
translated, and Defense Counsel will appreciate that if their speeches
are written down they can tell exactly how long they will take to deliver,
or almost exactly.

And there is one other thing I want to bring to their attention. There
are 20 or 21 defendants, and naturally, there are a variety of subjects
which are common to them a}l; and there ought to be, therefore, an opportunity,
as it appears to the Tribunal, for counsel to divide up the subjects to
some extent between them and not each one to deal with subjects which have
been dealt with already, any more than they ought to have been dealt with
in evidence over and over again; and I do not know whether Counsel for
Defense have fully considered that in making this estimate of the time
they laid before us.

Anyway, the Tribunal hopes that they will address their minds to these
three matters: First of all, as to whether they can submit their speeches
for translation in order to help the Tribunal; secondly, whether they will
be able, when they have got their speeches written down, to assess the
time accurately; and thirdly, whether they cannot apportion the subjects
to some extent among them so that we shall not have to listen to the same
subjects over and over again.

I do not know whether the Prosecution would wish to say anything. The
Tribunal has said, I think, in the order which we made with reference to
this question of limitation of time, that they anticipated that the Prosecution
would take only 3 days. Perhaps it would be convenient to hear from the
Prosecution whether that is an accurate estimate.

SIR DAVID MAXWELL-FYFE: Yes, My Lord, the Prosecution do not ask for
any more than the 3 days. It might conceivably be a little less, but we
do not ask for any more than the 3 days.

MR. JUSTICE JACKSON: I should like, Your Honor, to call your attention
to this. I hope it is not expected that we will mimeograph and run off
on our mimeograph machines, 20 days of speeches or anything of that sort.
We simply cannot be put under that kind of a burden. I think it isa citizen
of the United States is expected to argue his case in the highest court
of the land in one hour, and counsel's own clients here have openly scoffed
at the amount of time that has been asked. This is not a sensible amount
of time to give to this case, and I must protest against being expected
to mimeograph 20 days of speeches. It really is not possible.

PRESIDENT: The Tribunal would like to know whether the Prosecution intend
to let them have copies of their speeches at the time that they are delivered.

SIR DAVID MAXWELL-FYFE: As far as the closing speech of the Attorney
General is concerned, we certainly did expect and hope to give the Tribunal
copies of the speech.

THE PRESIDENT: And translations?

SIR DAVID MAXWELL-FYFE: Yes, that will be done. My Lord, I just wondered,
out of optimismit was Dr. Nelte who said that it would take a long time
to translate. I know, as far as translating into English is concerned,
we had the problem of a 76 page speech the other day, and that was done
by our own translators in one day. So I hope that perhaps Dr. Nelte has
been a little pessimistic about that side of the problem.

THE PRESIDENT: The Tribunal will consider the matter.

Now, the Tribunal will go on with the cross-examination.

[The Defendant Speer resumed the stand.]

MR. JUSTICE JACKSON: I think perhaps, Your Honor, the photographs in
evidence are left a little unintelligible, if the record does not show
the description of them. I shall read it briefly.

"Torture cabinets which were used in the foreign workers' camp in the
grounds of Number 4 Armor Shop and those in the dirty neglected Russian
Camp were shown to us, and we depose the following on oath:

"Photograph 'A' shows an iron cupboard which was specially manufactured
by the firm of Krupp to torture Russian civilian workers to an extent that
cannot possibly be described by words. Men and women were often locked
into a compartment of the cupboard, in which hardly any man could stand
up for long periods. The measurements of this compartment are: Height 1.52
meters; breadth and depth 40 to 50 centimeters each. Frequently even two
people were kicked and pressed into one compartment. The Russian..."

I will not read the rest of that.

"Photograph 'B' shows the same cupboard as it looks when it is locked.

"Photograph 'C' shows the cupboard open.

"In Photograph 'D' we see the camp that was selected by the Krupp Directorate
to serve as living quarters for the Russian civilian workers. The individual
rooms were 2 to 2.5 meters wide, 5 meters long, and 2 meters high. In each
room up to 16 persons were accommodated in double tier beds." (Document
USA-897)

I think that covers it.

THE PRESIDENT: Mr. Justice Jackson, one moment. I think you ought to
read the last three lines of the second paragraph, beginning, "At the top
of the cupboard..."

MR. JUSTICE JACKSON: Oh yes, I am sorry.

"At the top of the cupboard there are a few sievelike air holes through
which cold water was poured on the unfortunate victims during the ice-cold
winter."

THE PRESIDENT: I think you should read the last three lines of the penultimate
paragraph in view of what the defendant said about the evidence.

MR. JUSTICE JACKSON: "We are enclosing two letters which Camp Commandant
Lowenkamp had smuggled out of prison in order to induce the undersigned
Hofer to give evidence favorable to him."

And perhaps I should read the last:

"The undersigned, Dahm,"one of the signers"personally saw how three
Russian civilian workers were locked into the cupboard, two in one compartment,
after they had first been beaten on New Year's Eve 1945. Two of the Russians
ha to stay the whole of New Year's Eve locked in the cupboard, and cold
water was poured on them as well."

I may say to the Tribunal that we have upwards of a hundred different
statements and depositions relating to the investigation of this camp.
I am not suggesting offering them, because I think they would be cumulative,
and I shall be satisfied with one more, D-313, which would become Exhibit
USA-901, which is a statement by a doctor.

THE PRESIDENT: Mr. Justice Jackson, was this camp that you are referring
to a concentration camp?

MR. JUSTICE JACKSON: Well, it was, as I understand it, a prisoner-of-war
camp and a labor camp. There were labor camps and prisoner-of-war camps
at Essen. I had not understood that it was a concentration camp, but I
admit the distinction is a little thin at times.

This document reads:

"I, the undersigned, Dr. Apolinary Gotowicki, a physician in the Polish
Army, was taken prisoner by the Germans on 1/3/1941 and remained as such
until the entry of the Americans. I gave medical attention to the Russian,
Polish, and French prisoners of war who were forced to work in various
places of Krupp's factories. I personally visited the Russian POW camp
in the Raumastrasse in Essen, which contained about 1,800 men. There was
a big hall in the camp which could house about 200 men comfortably, in
which 300 to 400 men were thrown together in such a catastrophic manner
that no medical treatment was possible. The floor was cement and the mattresses
on which the people slept were full of lice and bugs. Even on cold days
the room was never heated and it seemed to me, as a doctor, unworthy of
human beings that people should find themselves in such a position. It
was impossible to keep the place clean because of the overcrowding of these
men who had hardly room to move about normally Every day at least 10 people
were brought to me whose bodies were covered with bruises on account of
the continual beatings with rubber tubes, steel switches, or sticks. The
people were often writhing with agony and it was impossible for me to give
them even a little medical aid. In spite of the fact that I protested,
made complaints and petitions, it was impossible for me to protect the
people or see that they got a day off from work. It was difficult for me
to watch how such suffering people could be dragged to do heavy work. I
visited personally, with danger to myself, gentlemen of the Krupp administration,
as well as gentlemen from the Krupp Directorate, to try to get help. It
was strictly forbidden, as the camp was under the direction of the SS and
Gestapo; and according to well-known directives I had to keep silent, otherwise
I might have been sent to a concentration camp. I have brought my own bread
innumerable times to the camp in order to give it to the prisoners, as
far as it was possible, although bread was scarce enough for me. From the
beginning in 1941 conditions did not get better, but worse. The food consisted
of a watery soup which was dirty and sandy, and often the prisoners of
war had to eat cabbage which was bad and stank. I could notice people daily
who, on account of hunger or ill-treatment, were slowly dying. Dead people
often lay for 2 or 3 days on the beds until their bodies stank so badly
that fellow prisoners took them outside and buried them somewhere. The
dishes out of which they ate were also used as toilets because they were
too tired or too weak from hunger to get up and go outside. At 3 o'clock
they were wakened. The same dishes were then used to wash in and later
for eating out of. This matter was generally known. In spite of this it
was impossible for me to get even elementary help or facilities in order
to get rid of these epidemics, illnesses, or cases of starvation. There
can be no mention of medical aid for the prisoners. I never received any
medical supplies myself. In 1941 I alone had to look after these people
from a medical point of view; but it is quite understandable that it was
impossible for me as the only one to look after all of these people, and
apart from that, I had scarcely any medical supplies. I could not think
what to do with a number of 1,800 people who came to me daily crying and
complaining. I myself often collapsed daily, and in spite of this I had
to take everything upon myself and watch how people perished and died.
A report was never made as to how the prisoners of war died.

"I have seen with my own eyes the prisoners coming back from Krupp's
and how they collapsed on the march and had to be wheeled back on barrows
or carried by their comrades. It was in such a manner that the people came
back to the camp. The work which they had to perform was very heavy and
dangerous and many cases happened where people had cut their fingers, hands
or legs. These accidents were very serious and the people came to me and
asked me for medical help. But it was not even possible for me to keep
them from work for a day or two, although I had been to the Krupp Directorate
and asked for permission to do so. At the end of 1941, two people died
daily, and in 1942 the deaths increased to three and four per day.

"I was under Dr. May and I was often successful in getting him to come
to the camp to see the terrible conditions and listen to the complaints,
but it was not possible for him to get medical aid from the Medical Department
of the Armed Forces or Krupp's, or to get better conditions, treatment,
or food. I was a witness during a conversation with some Russian women
who told me personally that they were employed in Krupp's factory and that
they were beaten daily in the most bestial manner. The food consisted of
watery soup which was dirty and inedible and its terrible smell could be
perceived from a distance. The clothing was ragged and torn and on their
feet they had rags and wooden shoes. Their treatment, as far as I could
make out, was the same as that of the prisoners of war. Beating was the
order of the day. The conditions lasted for years, from the very beginning
until the day the American troops entered. The people lived in great anxiety
and it was dangerous for them to describe to anyone anywhere the conditions
which reigned in their camps. The directions were such that they could
have been murdered by any one of the guards, the SS, or Gestapo if they
noticed it. It was possible for me as a doctor to talk to these people;
they trusted me and knew that I was a Pole and would never betray them
to anyone.

"Signed: Dr. Apolinary Gotowicki."

[Turning to the defendant.] Now you have explained that some of these
conditions were due, in your judgment, to the fact that bombing took place
and the billets of the prisoners and workers were destroyed.

SPEER: That is true, but I should like to point out that the conditions
described in this affidavit cannot be considered as general; apart from
that, I do not believe that this description is correct, but I cannot speak
about these things since you will not expect me to be intimately acquainted
with what happened in the camps of the firm of Krupp.

MR. JUSTICE JACKSON: Well, in the first place, was it considered proper
by you to billet forced workers and prisoners of war so close to military
targets as these prisoners were?

SPEER: I would rather not tell you here things which every German has
at heart. No military targets were attacked, and the camps, therefore,
could not be near military targets.

MR.JUSTICE JACKSON: You would not consider the Krupp plants proper targets?

SPEER: The camps were not in the Krupp works, they were near the city
of Essen. On principle, we did not construct camps near the works which
we expected would be bombed; and we did not want the camps to be destroyed.

MR. JUSTICE JACKSON: Did you notice that one of the photographs in evidence
shows the camp directly against the works?

SPEER: May I see it again, please?

[A photograph was shown to the defendant.]

Some large factory is recognizable in the background of this photograph,
but that does not affect my statement that in almost all cases we constructed
the camps outside the cities. I do not know why this particular instance
is different, and I cannot even say whether this is a camp or just a hut
for changing clothes, or anything which had to be near the camp. I still
believe that these cabinets were cabinets for clothes, and this is one
of the many huts which were necessary so that the workers could change
clothes before and after their work. Any expert in Germany can tell you
that these are wardrobes and not some special cabinets, because they are
mass-produced articles; this is also confirmed by the fact that there are
air vents at the top, for every wardrobe has these ventilation holes at
the top and.bottom.

MR.JUSTICE JACKSON: As production Minister, you were vitally interested
in reducing the sickness rate among workers, were you not?

SPEER: I was interested in a high output of work, that is obvious, and
in addition, in special cases. . .

MR.JUSTICE JACKSON: Well, special casespart of production is in all
cases, is it not, dependent upon the sickness rate of our labor force,
and is it not a factas a man engaged in production you will know thisthat
the two greatest difficulties in manpower and production are sickness and
rapid turnover, and that those factors reduce production?

SPEER: These two factors were disturbing for us, but not as extensively
as your words might suggest. Cases of sickness made up a very small percentage
which in my opinion was normal. However, propaganda pamphlets dropped from
aircraft were telling the workers to feign illness, and detailed instructions
were given to them on how to do it. And to prevent that, the authorities
concerned introduced certain measures, which I considered proper.

MR.JUSTICE JACKSON: What were those measures?

SPEER: I cannot tell you in detail, because I myself did not ,- institute
these penalties, nor did I have the power to do so; but as far as I know,
they were ordered by the Plenipotentiary General for the Allocation of
Labor in collaboration with the Police or State authorities; but the jurisdiction
in this connection was with the -authorities responsible for legal action.

MR. JUSTICE JACKSON: Now, if you did not know what they were, how can
you tell us that you approved of them? We always get to this blank wall
that
nobody knew what was being done. You knew that they were at least penalties
of great severity, did you not?

SPEER: When I say that I approved I am only expressing my wish not to
dodge my responsibility in this respect. But you must understand that a
minister of production, particularly in view of the air attacks, had a
tremendous task before him and that I could only take care of matters outside
my own field if some particularly important factor forced me to do so.
Otherwise, I was glad if I could finish my own work and, after all, my
task was by no means -a small one.

I think that if during the German air attacks on England you had asked
the British Minister of Production whether he shared the worries of the
Minister of Labor and whether he was dealing with them, then he would with
justification have told you that he had something else to do at that time,
that he had to keep up his production and that he expected the Minister
of Labor to manage affairs in his sector; and no one would have raised
a direct accusation against the British Minister of Production on that
account.

MR. JUSTICE JACKSON: Well, production was your enterprise, and do you
mean to tell me that you did not have any records or reports on the condition
of the manpower which was engaged in production, which would tell you if
there was anything wrong in the sick rate or anything wrong in the general
conditions of the labor?

SPEER: What I knew is contained in the reports of the Central Planning
Board; there you will get a picture of what I was told. Although there
were many other meetings I cannot tell you in detail what I knew, because
these were things outside my sphere of activity. Naturally, it is a matter
of course that anyone closely concerned with the affairs of State will
also hear of matters not immediately connected with his own sphere, and
of unsatisfactory conditions existing in other sectors; but one is not
obliged to deal with these conditions and later on one will not remember
them in detail. You cannot expect that of me. But if you have any particular
passage, I shall be glad to give you information on it.

MR.JUSTICE JACKSON: All right; assume that these conditions had been
called to your attention and that they existed. With whom would you have
taken it up to have them corrected? What officer of the Government?

SPEER: Normally, a minister would send a document to the Government
authorities responsible for such conditions. I must claim for myself that
when I heard of such deficiencies I tried to remedy them by establishing
direct contact with the authority responsible, in some cases the German
Labor Front, where I had a liaison officer, or in other cases my letter
was transmitted to Sauckel through my office of manpower deployment. My
practice in this respect was that if I ,did not receive a return report
I considered the matter settled; for I could not then again pursue those
things and make further inquiries whether they had been dealt with or not.

MR. JUSTICE JACKSON: With Krupp's, then, you would not have taken it
up? You think they had no responsibility for these conditions?

SPEER: During visits to Krupp's discussions certainly took place on
the conditions which generally existed for workers after air attacks; this
was a source of great worry for us, particularly with regard to Krupp.
I knew this well, but the reports from Krupp were not different fromI cannot
remember ever being told that foreign workers or prisoners of war were
in a particularly bad position. Temporarily they all lived under very primitive
conditions; German workers lived in cellars during those days, and six
or eight people were often quartered in a small basement room.

MR. JUSTICE JACKSON: Your statement some time ago that you had a certain
responsibility as a Minister of the Government for the conditionsI should
like to have you explain what responsibility you referred to when you say
you assume a responsibility as a member of the Government.

SPEER: Do you mean the declaration I made yesterday that I . . .

MR. JUSTICE JACKSON: Your common responsibility, what do you mean by
your common responsibility along with others?

SPEER: Oh, yes. In my opinion, a state functionary has two types of
responsibility. One is the responsibility for his own sector and for that,
of course, he is fully responsible. But above that I think that in decisive
matters there is, and must be, among the leaders a common responsibility,
for who is to bear responsibility for developments, if not the close associates
of the head of State?

This common responsibility, however, can only be applied to fundamental
matters, it cannot be applied to details connected with other ministries
or other responsible departments, for otherwise the entire discipline in
the life of the State would be quite confused, and no one would ever know
who is individually responsible in a particular sphere. This individual
responsibility in one's own sphere must, at all events, be kept clear and
distinct.

MR. JUSTICE JACKSON: Well, your point is, I take it, that you as a member
of the Government and a leader in this period of time acknowledge a responsibility
for its large policies, but not for all the details that occurred in their
execution. Is that a fair statement of your position?